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General Manager Campbelltown Council PO Box 57 Campbelltown NSW 2560 23 December 2016 Attn: Rad Blagojevic RE Application Number 2675/2008/DA-S Proposed subdivision of land at Kellerman Drive, St Helens Park Thank you for the opportunity to make a submission on the abovementioned application for the subdivision of land (Subdivision) at Kellerman Drive, St Helens Park (Site). As Green NSW Spokesperson for the Environment, I have significant concerns regarding the impact the Subdivision and the proposed development will have on local wildlife and biodiversity. The proposal is for the construction of 355 allotments at the Site, which I understand will involve the clearing of around 30 ha of bushland and the removal of hundreds of native trees on the Site. The region is a vibrant piece of biodiversity in NSW, and it is my concern that the proposal will have devastating consequences on native vegetation and wildlife (including threatened species) on the proposed development land. In particular, the St Helens Park bushland is unique in that it supports a healthy koala population. Dr Robert Close, foremost koala expert in the Campbelltown region, estimates that a colony of at least six chlamydia-free koalas inhabit the Site. Reports and koala sightings in the region indicate that the Site is most likely no longer transitory for the koala population, but a permanent habitat. The survival of this koala colony, as well as other such koala colonies throughout NSW, are already threatened by a number of factors, including climate change, bushfires, predation by both domestic and non-native animals, and motor vehicle accidents. However, the loss and degradation of their habitat and land clearing (including from residential developments such as the proposed development) are the most significant threats facing koala populations in NSW. Koalas have suffered considerable decline in numbers and distribution in recent history, with a third of NSW’s koala population declining since 1990 1 and most populations now surviving in fragmented and isolated habitats. As a result, koalas are threatened species, and have been listed as Vulnerable under both the Threatened Species Conservation Act 1995 (NSW) (TSC Act) (repealed, and soon to 1 Commonwealth Department of Environment and Energy, Koala (combined populations of Queensland, New South Wales and the Australian Capital Territory), http://www.environment.gov.au/cgibin/sprat/public/publicspecies.pl?taxon_id=85104. be replaced by the Biodiversity Conservation Act 2016 (NSW)) and under the Environmental Protection Biodiversity Conservation Act 1999 (Cth) (EPBC Act). I understand that this action may require an assessment of significance under the Environmental Planning and Assessment Act 1979 (EP&A Act) and a species impact statement may also be required under the Threatened Species Conservation Act 1995 or the Biodiversity Conservation Act 2016. I would be most grateful if you could confirm whether these have been carried out, and if not, why they have not been prepared. In addition to the koala colony, the Cumberland Plain Woodlands are made up of a diverse body of flora found on clay soils derived from shale, distinct to the Cumberland Plain. Specifically, the Shale Sandstone Transition Forest found in the area is listed as critically endangered under the Threatened Species Conservation Act 1995 and its successor, the Biodiversity Conservation Act 2016. The Cumberland Plains Woodland Snail which inhabits the area is also listed as critically endangered. Land clearing and urban development are the two primary threats to the species survival. Notwithstanding the development undergoing the proper evaluation and impact assessment processes, I urge Council to reject the Subdivision. Further land clearing and urban expansion will have dire consequences for the koala colony and other native flora and fauna on the Site. These consequences will be irreversible if the proposed development goes ahead. Further, as the impacts of climate change takes hold, parcels of biodiversity, like the subject land, are even more vital as biodiversity corridors. The proposal is also inconsistent with the expectations of a large proportion of the local community, many of whom have expressed staunch opposition to the Subdivision and proposed development. To date, over 1,600 individuals have signed an online petition opposing the development on the grounds of preserving the native flora and fauna, and opposing further urban expansion. Indeed, there are calls for St Helens Park and the surrounding region to be a designated koala conservation area, and protected from further habitat loss. The Council must give weight to these concerns, and not compromise biodiversity in the region for short-term commercial gains. As you are no doubt aware, the passage of the Biodiversity Conservation Act 2016 (NSW) will severely weaken environmental protection laws across the state once it comes into effect in February 2017. More than ever, it is incumbent upon Local Government to protect the native fauna and flora in their jurisdiction, particularly those areas of ecological significance. Thank you for your consideration. Dr Mehreen Faruqi MLC NSW Greens Environment Spokesperson